Changes in Store for Many Industrial Stormwater Permit Holders in Oregon

Hundreds of Oregon industrial stormwater permits will be affected by a recent settlement agreement between the Oregon Department of Environmental Quality (DEQ), the Columbia Riverkeeper and Northwest Environmental Defense Center, and the Oregon Industrial Stormwater Group. The agreement aims to resolve conflict surrounding the current NPDES Permit No. 1200-Z Industrial Stormwater General Permit (1200-Z Permit) issued by DEQ on August 1, 2017. For 1200-Z Permit holders, the agreement will bring both short-term effects and potentially longer term changes to the process for developing proposed effluent limitations, benchmarks, or other narrative conditions in the future revised 1200-Z Permit.

Outcomes of the Settlement Agreement

• Increases the frequency of required Discharge Monitoring Report submittals from annually to quarterly.
• Increases the frequency of sampling for impairment pollutants from twice annually to four times annually.
• Requires that when an impairment reference concentration is exceeded, a Tier I Corrective Action report must be submitted to DEQ or its agent no later than 60 calendar days after monitoring results are received. Currently, Tier I reports are not required to be submitted to DEQ or its agent.
• Changes sampling requirements for commingled discharges associated with industrial activity and run-on.
• Enacts process changes that could result in establishment of effluent limitations either at a site-specific level or state-wide. Current benchmarks are guideline concentrations, and exceedance of a benchmark does not represent a permit violation. Exceedance of an effluent limitation, however, would constitute a permit violation that could result in enforceable actions for each violation.

These changes affect current 1200-Z Permit holders. DEQ reissued the revised 1200-Z Permit on October 22, 2018.

Integral has extensive experience with stormwater permitting issues and provides a wide range of stormwater services, including compliance support and source control assistance for Portland Harbor industries. We actively facilitate the execution and management of NPDES industrial stormwater general permits for numerous clients. Our award-winning stormwater projects have fulfilled regulatory requirements, improved ecological habitats, and been recognized for excellence by DEQ.

For more information or assistance, please contact Andrew Halmstad at (503) 943-3633 or ahalmstad@integral-corp.com.